British authorities have provided manufacturers updated information on how to handle products coming from EU to UK market from 1 January 2021.


While Brexit trade negotiations – including the principles of mutual recognition – enter their final leg, the UK government has issued some guidance intended to give manufacturers and users clarity on the rules which will apply after the transitional period ends on 31 December 2020.

Products placed on the UK market (with the exception of Northern Ireland, where EU-compliant products are still accepted) will need to comply as follows:

For wheeled tractors (category T), the rules remain similar compared to what was originally planned in case of a hard Brexit: by 31 December 2020, all tractor types intended to be sold on the UK market will need to be declared to the UK authorities through their EU-type approvals (which includes their extensions). They will receive a provisional GB type-approval applicable till the end of 2022. These tractors will be able to be provided with the EU statutory plate and the EU Certificate of Conformity on the UK market. The request for a provisional GB type-approval will be required for the whole vehicle only, not its components.

Within these two years, the manufacturer will have to proceed to a full GB type-approval, for which the technical requirements will be available in 2021. For this GB type-approval, it is advised to provide all the information to the UK authorities by June 2022 to avoid bottlenecks.

For road requirements on self-propelled machinery, agricultural tracked tractors (category C), agricultural trailers (category R), interchangeable towed equipment (category S) and components like engines, nothing will be required from 1 January 2021: the new requirements will be published in 2021 for an expected application from 1 January 2022.

For products originally associated to a CE mark, a UKCA mark will be required from 1 January 2021. One additional year may be allowed:

  • On self-declared products
  • When there is a third-party assessment carried out by an EU-recognised Notified Body
  • When there is a Certificate of conformity originally held by UK authority and transferred to an EU-recognised Notified Body

These exemptions do not apply when the product-specific UK Regulation already imposes the UKCA mark.

The need for marking on products fitted in type-approved vehicles is still a pending question.

It is reminded the importance to have a legal representative in UK to represent the manufacturer.

More information can be retrieved at the links below:

Placing manufactured goods on the market in Great Britain from 1 January 2021

Placing manufactured goods on the EU market from 1 January 2021

Using the UKCA mark from 1 January 2021

Conformity assessment bodies: change of status from 1 January 2021

UK REACH Regulation

Issuing GB type approval from 1 January 2021